On November 28, 2022 a
Party Discovery
was filed
involving a dispute between
and
Dolgencorp Llc,
for Circuit Civil
in the District Court of Lake County.
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35-2022-CA-002134-AXXX-XX
Filing # 161892720 E-Filed 11/28/2022 11:46:02 AM
IN THE CIRCUIT COURT, FIFTH
JUDICIAL CIRCUIT, IN AND FOR
LAKE COUNTY, FLORIDA
CASE NO.:
DIVISION:
MELISSA MAGLIO,
an individual,
Plaintiff,
Vv.
DOLGENCORP, LLC,
A Foreign Limited Liability Company,
Defendant.
/
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION TO THE
DEFENDANT, DOLGENCORP, LLC
Pursuant to the applicable Rules of Civil Procedure, the DOLGENCORP, LLC,
is hereby requested to produce for inspection and copying by the plaintiffs and their attorneys, all
documents described below which are in the possession, custody or control of the defendant.
Production shall be made at the Law Office of Nooney & Roberts, 1680 Emerson Street,
Jacksonville, Florida, 32207, within thirty days of service hereof.
Any written reports made or any written statements taken from witnesses about
the incident described in the Complaint.
Any photographs taken or videotapes made which relate to liability, damages, or
any other issues concerning the incident described in the Complaint.
Any items of physical evidence, including any objects, substances, diagrams,
measurements, plans, blueprints, documents, letters, or any other tangible items
obtained which relate to the incident described in the Complaint.
Any records regarding regular floor cleaning or repairs performed at the premises
described in the Complaint during the three months prior to this incident.
Any records regarding regular floor cleaning performed at the premises described
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 11/28/2022 02:51:17 PM
in the Complaint subsequent to this incident.
Describe floor cleaning or maintenance procedures performed by Defendant
employee and/or janitorial staff within 24 hours prior to incident on May 7, 2021
Describe safety training measures provided to Defendant’s employees prior to
May 7, 2021.
Any written manuals, policies, or procedures pertaining to safety precautions or
maintenance policies in this regard.
Any records of any incidents involving persons who claimed to have sustained a
fall on these premises during the three years prior to the incident described in the
Complaint.
10 Any records of any incidents involving persons who claimed to have sustained a
fall on these premises since the date of the incident described in the Complaint.
11 Copies of the declarations pages of all policies of insurance which you contend
cover or may cover you for the allegations set forth in the Complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28" day of November 2022, I electronically filed
the foregoing document with the Clerk of the Court using the Florida Courts E-Filing Portal.
LAW OFFICE OF NOONEY,
ROBERTS, HEWETT & NOWICKI
/s/ Lisa M. Nommensen.
Lisa M. Nommensen, Esq.
Florida Bar No. 124203
1680 Emerson Street
Jacksonville, FL 32207
Phone: (904) 398-1992
Fax: (904) 858-9943
Lisa@nrhnlaw.com
Attorney for the Plaintiff
Document Filed Date
November 28, 2022
Case Filing Date
November 28, 2022
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35-2022-CA-002134-AXXX-XX Filing # 161892720 E-Filed 11/28/2022 11:46:02 AM IN THE CIRCUIT COURT, FIFTH JUDICIAL CIRCUIT, IN AND FOR LAKE COUNTY, FLORIDA CASE NO.: DIVISION: MELISSA MAGLIO, an individual, Plaintiff, Vv. DOLGENCORP, LLC, A Foreign Limited Liability Company, Defendant. / PLAINTIFF’S FIRST REQUEST FOR PRODUCTION TO THE DEFENDANT, DOLGENCORP, LLC Pursuant to the applicable Rules of Civil Procedure, the DOLGENCORP, LLC, is hereby requested to produce for inspection and copying by the plaintiffs and their attorneys, all documents described below which are in the possession, custody or control of the defendant. Production shall be made at the Law Office of Nooney & Roberts, 1680 Emerson Street, Jacksonville, Florida, 32207, within thirty days of service hereof. Any written reports made or any written statements taken from witnesses about the incident described in the Complaint. Any photographs taken or videotapes made which relate to liability, damages, or any other issues concerning the incident described in the Complaint. Any items of physical evidence, including any objects, substances, diagrams, measurements, plans, blueprints, documents, letters, or any other tangible items obtained which relate to the incident described in the Complaint. Any records regarding regular floor cleaning or repairs performed at the premises described in the Complaint during the three months prior to this incident. Any records regarding regular floor cleaning performed at the premises described FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 11/28/2022 02:51:17 PM in the Complaint subsequent to this incident. Describe floor cleaning or maintenance procedures performed by Defendant employee and/or janitorial staff within 24 hours prior to incident on May 7, 2021 Describe safety training measures provided to Defendant’s employees prior to May 7, 2021. Any written manuals, policies, or procedures pertaining to safety precautions or maintenance policies in this regard. Any records of any incidents involving persons who claimed to have sustained a fall on these premises during the three years prior to the incident described in the Complaint. 10 Any records of any incidents involving persons who claimed to have sustained a fall on these premises since the date of the incident described in the Complaint. 11 Copies of the declarations pages of all policies of insurance which you contend cover or may cover you for the allegations set forth in the Complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 28" day of November 2022, I electronically filed the foregoing document with the Clerk of the Court using the Florida Courts E-Filing Portal. LAW OFFICE OF NOONEY, ROBERTS, HEWETT & NOWICKI /s/ Lisa M. Nommensen. Lisa M. Nommensen, Esq. Florida Bar No. 124203 1680 Emerson Street Jacksonville, FL 32207 Phone: (904) 398-1992 Fax: (904) 858-9943 Lisa@nrhnlaw.com Attorney for the Plaintiff